Nuclear 1 Environmental Impact Assessment Deidre Herbst Eskom Environmental Manager Doc ID

Background Environmental Impact Assessments (EIA’s) became a legal requirement in South Africa in 1997. It was at this time that Eskom was progressing with plans for additional capacity. The first two EIA’s carried out were for the Ingula pumped storage scheme and the Pebble Bed Modular Reactor. These were followed by EIA’s for coal fired power stations: Medupi, Kusile, a site in the Vaal region, Steelpoort pumped storage scheme, Ankerlig and Gourikwa open cycle gas turbines. The Nuclear 1 EIA was initiated in 2006. The first public meetings and the draft scoping report were published in 2007. Environmental Authorisations were obtained for Medupi, Kusile, Ankerlig, Gourikwa within 1 – 2 years from appointing consultants.

Challenges in obtaining an Environmental Authorisation Ingula Pumped Storage Scheme is situated on the escarpment. The upper dam is situated in sensitive high altitude grasslands and impacted on an extensive wetland. The Environmental authorisation was appealed and the appeal upheld by the Minister of Environmental Affairs An application was made to the Court, the Minister reviewed his decision based on the strategic importance of new generating capacity. EA was granted in 2004 (EIA process of 6 years)

Challenges Continued Pebble Bed Modular Reactor there were two EIA processes First EIA, Environmental Authorisation received within 3 years (2000-2003) but taken on court review. Court decision determined additional stakeholder engagement was required. Design changes – new EIA required. Second EIA was never completed due to discontinuation of the project. The preferred site for PMBR was the Koeberg site.

Nuclear 1: EIA Process Eskom appointed an independent Environmental Assessment Practitioner, Arcus Gibb, to carry out the Environmental Impact Assessment (EIA) The EIA process, which commenced in 2007, has been extensive with more than 60 public interventions (public meetings, key stakeholder workshops, focus group meetings, open days) in 4 separate public comment periods. The duration of the public comment periods was more than 60 days, with 106 days for the draft impact report. (the norm is 45 days for complex EIA’s) The application is for one power station of up to 4000MW installed capacity, on one site Five sites were selected and evaluated during the scoping phase Three sites were taken forward into the Environmental Impact Assessment phase (subsequent to DEA approval to remove the Northern Cape Sites): 2018/11/13

Identified Sites

Transmission Lines associated with alternative sites 2018/11/132018/11/132018/11/132018/11/13

Thyspunt has been proposed as the preferred site.

Nuclear 1 history and potential challenges The scoping phase: 2006 to 2008 approval of final scoping report. The DEA approved the Plan of Study for EIA in January 2010 The Draft EIR was prepared and provided for public comment from 6 March 2010. The period for comment on the Draft EIR was lengthened twice, and the end of the lengthened comment period was 30 June 2010 Due to comments received during this period, the EIA team decided to revise selected specialist reports and provided a Revised Draft EIR (Version 1) for public review from 6 March to 07 August 2011

Project Challenges - New Issues from the DEA The DEA after a lengthy review process requested additional studies hence the Revised Draft EIR Version 2 was prepared Site selection methodology Biodiversity offsets Duynefontein regarded as a greenfield site Independent review of all specialist studies required Cumulative assessment considering Transmission EIA for each site Infrastructure assessment relating to each site Radiological safety assessment Design basis accidents assessment with specific reference to Fukushima The Revised Draft EIR version 2 will be made available for public comment in 2015.

Specialist Studies 1). Geology and geological risk 2). Seismological risk 3). Geotechnical suitability 4). Hydrological 5). Geo-hydrological 6). Freshwater supply 7). Air quality and climate 8). Dune geomorphology 9). Botanical 10). Freshwater ecology (wetland) 11). Terrestrial vertebrate fauna 12). Terrestrial invertebrate fauna 13). Marine biology (Revised) 14). Economic impact 15). Social impact 16). Visual impact 17). Heritage impact (Revised) 18). Agricultural impact 19). Tourism impact 20). Noise impact 21). Human health risk 22). Transportation (Revised) 23). Emergency response 24). Site control and access 25). Nuclear waste disposal 26). Integration with the transmission network 27). Estimating the 1:100 year flood line from the sea 28). Oceanographic impact assessment 29) Town planning 30) Radiological 31)Biodiversity (considering offsets)

Main Issues of Concern for the Public Technology – Gen III, Perception around safety, Radioactive waste management, Emergency planning, Roads Infrastructure, Impact on squid industry, Construction camps/ villages, Impact on Spatial Planning, Conservation Value, Agricultural impacts from radiation, Seismic design, etc Heritage Resources 2018/11/13

Concluding remarks Since Fukishima there has been an increase in the anti nuclear lobby and this is visible given the increased participation of organisations such as Greenpeace in the last rounds of public participation. While the content of the EIA is comprehensive and complete, legal challenges are often made in terms of process and not in terms of environmental impacts. Any changes in the technology envelope may result in the authorities requiring a new EIA to be initiated. Reliance is placed on the DEA to review the Final Environmental Impact Report within legislated timeframes. New appeal regulations provide legislated timelines of between 3 – 4 months. The decision can be challenged in a Court of law, this process could result in lengthy delays.

Timelines and Way Forward The following timelines are anticipated: April 2015 – avail the Draft EIR version 2 for public review May June 2015 – conduct public meetings September 2015 – submit final report to the DEA These timelines are depended on the methodology workshop to be held with the DEA in March 2015.

Thank You Thyspunt Dunes after summer rainfall 2011